# MID - VALLEY PIPELINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 220175002M
- **title:** MID - VALLEY PIPELINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-04-12
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.402(c)(3).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220175002m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220175002m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220175002m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220175002M
**body:**

Notice of Amendment involving MID - VALLEY PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2017-04-12 and is reported as closed as of 2017-11-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220175002M_Closure Letter_11142017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Closure%20Letter_11142017.pdf

220175002M_Notice of Amendment_0412017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Notice%20of%20Amendment_0412017_text.pdf

220175002M_Notice of Amendment_04122017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Notice%20of%20Amendment_04122017.pdf

220175002M_Operator Response to Notice_05172017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Operator%20Response%20to%20Notice_05172017.pdf

220175002M_Notice of Amendment_0412017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 12, 2017
Mr. David Chalson
Senior Vice President, Operations
Mid-Valley Pipeline Company
401 Market Street
Aston, PA 19014
CPF 2-2017-5002M
Dear Mr. Chalson:
On September 12-15, 2016, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the
Mid-Valley Pipeline Co. (MVPL) corrosion control procedures and records at your office in
Hebron, Kentucky, pursuant to Chapter 601 of 49 United States Code.
On the basis of the inspection, PHMSA has identified apparent inadequacies within the
MVPL written corrosion control procedures as described below:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by paragraph
(a) of this section must include procedures for the following to provide safety during
maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance
with each of the requirements of this subpart and subpart H of this part.
MVPL’s corrosion control procedures do not contain adequate instruction on entering
data into MVPL’s corrosion control database.
MVPL Procedure OQP-011, titled Conduct Annual Survey, includes the following
sections, as related to corrosion control data entry:
1.10. DOCUMENT all readings on the appropriate record form OR CAPTURE
reading with data logger.



1.11. RECORD OR TRANSFER readings onto appropriate computer program AND
REPORT all measurements to the SPLP Engineering Department.”
Per field interviews and PHMSA record review, MVPL personnel regularly enter values
of “999”, “-999” or “0” into the corrosion database as a means of indicating that a valid
pipe-to-soil (p/s) potential reading could not be made at a given test station. MVPL
Procedure OQP-011 referenced above does not contain any instruction on this practice.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document
you must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in
this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as
alleged in this Notice without further notice to you and to issue an Order Directing
Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you
may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.
§ 190.206). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 30 days of receipt of this Notice. This period may be extended
by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that MVPL maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/ revision of plans,
procedures) and submit the total to the Director, Southern Region – Office of Pipeline Safety,
Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this
matter, please refer to CPF 2-2017-5002M and, for each document you submit, please
provide a copy in electronic format whenever possible.
Sincerely,
James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
2

220175002M_Closure Letter_11142017.pdf

•
U.S. Department
233 Peachtree Street Ste. 600
of Transportation
Atlanta, GA 30303
Pipeline and
Administration
Hazardous Materials Safety
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 14, 2017
Mr. David Chalson
Senior Vice President, Operations
Mid-Valley Pipeline Company
401 Market Street
Aston, PA 19014
CPF 2-2017-5002M
Dear Mr. Chalson:
On September 12-15, 2016, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the
Mid-Valley Pipeline Co. (MVPL) corrosion control procedures and records at your office in
Hebron, Kentucky, pursuant to Chapter 601 of 49 United States Code. As a result of the
inspection, PHMSA issued a Notice of Amendment (NOA) on April 12, 2017.
The OPS Southern Region has received and reviewed MVPL's response dated May 17, 2017.
Based on our review of these responses we have determined that MVPL has complied with
the terms of the NOA. This case is now closed and no further action is necessary with respect
to the matters involved in this case.
Please be advised that this letter refers only to the referenced NOA (CPF 2-2017-5002M) and
not to any other PHMSA cases, if any.
Sincerely,
I-ce
James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region

220175002M_Notice of Amendment_04122017.pdf

U.S. Department
233 Peachtree Street Ste. 600
of Transportation
Atlanta, GA 30303
Hazardous Materials Safety
Pipeline and
Administration
NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 12, 2017
Mr. David Chalson
Senior Vice President, Operations
Mid-Valley Pipeline Company
401 Market Street
Aston, PA 19014
CPF 2-2017-5002M
Dear Mr. Chalson:
On September 12-15, 2016, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the
Mid-Valley Pipeline Co. (MVPL) corrosion control procedures and records at your office in
Hebron, Kentucky, pursuant to Chapter 601 of 49 United States Code.
On the basis of the inspection, PHMSA has identified apparent inadequacies within the
MVPL written corrosion control procedures as described below:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a)
(c)
Maintenance and normal operations. The manual required by paragraph
(a) of this section must include procedures for the following to provide safety during
maintenance and normal operations:
(1)
(3) Operating, maintaining, and repairing the pipeline system in accordance
with each of the requirements of this subpart and subpart H of this part.
MVPL's corrosion control procedures do not contain adequate instruction on entering
data into MVPL's corrosion control database.
MVPL Procedure OQP-011, titled Conduct Annual Survey, includes the following
sections, as related to corrosion control data entry:
1.10.DOCUMENT all readings on the appropriate record form OR CAPTURE
reading with data logger.



1.11. RECORD OR TRANSFER readings onto appropriate computer program AND
REPORT all measurements to the SPLP Engineering Department."
Per field interviews and PHMSA record review, MVPL personnel regularly enter values
of "999", "-999" or "O" into the corrosion database as a means of indicating that a valid
pipe-to-soil (p/s) potential reading could not be made at a given test station. MVPL
Procedure OQP-011 referenced above does not contain any instruction on this practice.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document
you must provide a second copy of the document with the portions you believe quality for
confidential treatment redacted and an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in
this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as
alleged in this Notice without further notice to you and to issue an Order Directing
Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you
may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.
§ 190.206). If you are not contesting this Notice, we propose that you submit your amended
procedures to my office within 30 days of receipt of this Notice. This period may be extended
by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed
It is requested (not mandated) that MVPL maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/ revision of plans,
procedures) and submit the total to the Director, Southern Region - Office of Pipeline Safety,
Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this
matter, please refer to CPF 2-2017-5002M and, for each document you submit, please
provide a copy in electronic format whenever possible.
Sincerely,
Derick h. Turner
For James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
2
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